Recently, the Implementation Procedures for Airworthiness (IPA) respectively signed by Civil Aviation Administration of China and Federal Aviation Administration of USA has officially come into force. The IPA, developed in accordance with the Agreement between the Governments of the People’s Republic of China and the United States of America for Promotion of Aviation Safety, realized overall equivalence and mutual recognition of civil aviation products between the two countries, with the content covering airworthiness certification cooperation in multiple aspects of design approval, production surveillance activities, export airworthiness approval and post-design approval activities and technical support. The overall equivalence and mutual recognition of aviation products between China and the U.S. realized via IPA will create favorable bilateral environment for exchanges on civil aviation products and cooperation between industry departments. The official inking of IPA means the negotiations over the past 5 years reached expected results, which, under the principle of “seeking common ground while reserving differences”, will enable a bigger room for China-made aviation products to be exported to U.S. or even the global market.

Overall equivalence—Result of years’ efforts

While safety represents the foundation for civil aviation to develop, airworthiness certification is the important guarantee for civil aviation to be safe. Regulations of the People’s Republic of China on the Administration of the Airworthiness of Civil Aircraft, published in 1987, specified the principle of airworthiness management in its Article 1, i.e. “ensuring safety in civil aviation, protecting public interests and promoting the development of civil aviation undertakings”. Therefore, airworthiness management, with the purpose of protecting the safety and interests of the public, is to implement technical verification and supervision of the design, production, utilization and maintenance of civil aircraft and other relevant aviation products.

At present, U.S. is the biggest civil aviation market in the world, and airworthiness certification is the legal prerequisite for civil aviation products to enter market. Civil aviation regulators specify the standards and operation status that shall be reached by civil aircrafts operated within their states via regulations and rules, and issue airworthiness certificates for qualified aircraft, and aviation manufacturers need to pass the airworthiness certification of the state for their products to access that market. The signing of China-U.S. IPA means China and U.S. agree to recognize each other’s certification, creating a favorable bilateral environment for Chinese aviation products to be exported to U.S. To develop civil aircraft, airworthiness should go first, and the technical development of aviation industry and airworthiness management capabilities advance hand in hand. As early as over 20 years ago, China and U.S. started the tough negotiations on bilateral verification of airworthiness certificate. In 1995, China and U.S. signed the detailed rules on implementation procedures of China-U.S. bilateral airworthiness agreement, where it is specified that China recognizes the Airworthiness Certificate for Export of aircraft engines and propellers and airworthiness approval documents for export of equipment, parts and materials issued by FAA as civil aviation authority of the exporting country. As a result, China fully recognized all articles of FAA while FAA only recognized aircraft and some parts governed under FAR Part 23.

In 2017, as China’s aviation industrial capabilities and airworthiness certification capabilities further grew, the newly signed IPA realized overall equivalence and mutual recognition of aviation products manufactured by the two countries, covering large aircraft, small aircraft, helicopters, engines, propellers and parts. On this basis, major Chinese aviation products can enter the U.S. market via recognition channel, which is, as relevant person in charge of CAAC Department of Aircraft Airworthiness Certification put it, “not only beneficial for Chinese aviation product manufacturers to expand the U.S. market, but also good for Chinese aviation product manufacturers to form mature industry chain and optimize industrial resources.”

Agree to disagree—New goal in the new era

During this China-U.S. bilateral airworthiness negotiation, to “agree to disagree” refers to respecting law and regulation requirements of both parties, while realizing common targets through this document, which is the key and major difficulty during the negotiation.

“For a bilateral document on airworthiness, the most important part is the scope and procedures of mutual recognition.” Relevant person in charge from CAAC Department of Aircraft Airworthiness Certification introduced that IPA is a procedural document, and the recognition procedures can be categorized as acceptance procedures and recognition review procedures. “For a domestically manufactured aircraft to be exported to U.S., it needs to go through recognition review. CAAC encourages and supports Chinese enterprises to apply for FAA’s type recognition, such as ARJ21 and C919 of Commercial Aircraft Corporation of China Ltd.”

The signing of China-U.S. IPA also reflects improved mutual trust in bilateral cooperation in airworthiness between the two countries. As it is known that China-Europe bilateral airworthiness negotiation is undergoing, relevant person in charge from CAAC Department of Aircraft Airworthiness Certification expressed that China and Europe will also enhance cooperation, and jointly promote China-Europe Airworthiness Implementation Procedures to be signed soon.

During the 2017 National Civil Aviation Work Meeting & Aviation Safety Work Meeting, CAAC Party Group initiated eight salient characteristics for a country with a strong civil aviation, one of which is spearheading and having a say in international civil aviation rules and standards making. On October 27, CAAC Administrator Feng Zhenglin pointed out at Civil Aviation Airworthiness Certification Work Symposium that the industry should constantly enhance airworthiness certification capability building, lay a solid foundation for airworthiness certification, expand international export of airworthiness certification capabilities, so as to realize the transformation from a “rule-follower” to a “rule-maker”, and gradually develop the capability to export Chinese civil aviation airworthiness rules and standards to the global civil aviation community. As significant progress was made in China-U.S. airworthiness bilateral work, Airworthiness Certification Center of CAAC was officially inaugurated, focusing on the core tasks of “making up for the weak links of airworthiness and improving airworthiness certification capabilities”. The Center is endeavoring to strengthen its capabilities, to provide full-lifecycle airworthiness support service for Chinese-made civil aviation products to “go global”.